The parties agree that BIT arbitration falls under the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards
("New York Convention"), which governs agreements that are "commercial and... not entirely between citizens of the United States." Motorola Credit Corp. v. Uzan,
388 F.3d 39, 49 (2d Cir. 2004) (internal quotation marks omitted).6
The New York Convention "promote[s] the enforcement of arbitral agreements in contracts involving international commerce so as to facilitate international business transactions... Smith/Enron Cogeneration Ltd. v. Smith Cogeneration Int'l, Inc.,
198 F.3d 88, 92 (2d Cir. 1999) (internal quotation marks omitted). The Federal Arbitration Act ("FAA") implements the New York Convention, Motorola Credit Corp.,
388 F.3d at 49, and brings with it "a national policy favoring arbitration of claims that parties contract to settle in that manner," Vaden v. Discover Bank,
129 S. Ct. 1262, 1271 (2009) (internal quotation marks omitted).